Conflict of Interest Policy Disclosure

Campbell, Lee & Ross Investment Management Inc. (CLRIM) conflict of interest disclosure


         I.        PURPOSE

The purpose of this policy is to protect the interests of CLRIM and its clients. In the regular course of business, agents and employees of CLRIM may have the opportunity to advance their own personal interests with or against the interests of CLRIM and its clients. Acting in such a manner is unacceptable and any party who acts outside the best interests of its clients or of CLRIM may be subject to disciplinary action.

       II.        DEFINITIONS

a. Employee – Any person who is employed by CLRIM in a part-time or full-time capacity and in accordance with the labour laws as outlined in the province of Ontario.

b. Agent – An owner, director, stakeholder, contractor, or other third-party that is in the position to act on behalf of CLRIM.

c. Financial Interest – The interest that any individual may have in the monetary/financial transactions of CLRIM. In particular, any interest that could have a direct bearing on the financial gain/loss of any individual or client engaged in securities trading.

d. A material personal interest:

·         an ownership or investment interest in any entity with which this organization has a transaction or arrangement

·         a compensation arrangement with the organization or with any entity or individual with which the organization has a transaction or arrangement

·         a potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the organization is negotiating a transaction or arrangement

e. Client – Any account/household managed by CLRIM on behalf of its client base in a discretionary capacity. It is the duty of CLRIM and its employees to act in the best interest of its clients when engaging in financial transactions or associations that may impact this capacity.


      III.        PROCEDURE

a. Duty to disclose

Every employee/agent of CLRIM is obligated to disclose any known or potential conflicts of interest as soon as they arise and should act in a professional capacity that always puts the interest of its clients first. The Chief Compliance Officer and their team will need to be informed of any potential conflicts as soon as they are recognized so they may be catalogued and reviewed.

b. Investigating potential conflicts

When a possible conflict of interest arises, the board of directors will collect all of the pertinent information and may question any concerned parties. If the board determines that a conflict exists, steps will be taken to address the conflict. If no conflict exists, the inquiry may be documented but no further action will be taken.

c. Addressing conflicts of interest

When an actual conflict of interest is found, any transactions that may have been affected will be reviewed retroactively. Affected parties both within and outside of the business, including clients, shareholders, directors, employees, and contractors will be notified. An investigation will also be conducted by the board of directors to determine the extent of the conflict and the intentions of the parties involved.

If the conflict in question involves a member or members of the board of directors, such a member will be excused from the deliberations.

d. Disciplinary action

As all conflicts of interest will be reviewed on a case-by-case basis, a review may result in disciplinary action. The board of directors has full discretion to deem what disciplinary action is both fitting and necessary, including suspension and/or termination of employment.

     IV.        Importance

The following policy as part of new Client Focused Reform (CFR) requirements governed by the Ontario Securities Commission (Regulators) and National Instrument 31-103, outlines the importance our firm places on conflict-of-interest disclosure and its impact on our clients.

      V.        Acknowledgment

All employees of CLRIM understand the procedure for conflicts of interest including their duty to disclose any known or potential conflicts and the impact this may have on its client’s.

Furthermore, all employees or agents agree to abide by the procedures outlined in this policy and the procedures outlined in its Code of Conduct and Ethics policy for the duration of their professional relationship under CLRIM and at no time will engage in any practices that may be deemed illicit in any capacity.



Campbell, Lee & Ross Investment Management Inc.